Anti-Corruption Guidelines

U. Del Corona & Scardigli S.r.l. believes that ethics in business conduct promotes entrepreneurial activities by spreading an image of loyalty, transparency, fairness, and reliability. For this reason, the Company’s primary objective is to conduct all its activities in compliance with current regulations, not only encouraging but demanding that relationships with external parties are based on adherence to laws, regulations, and what is established in its Code of Ethics.

In general, anti-corruption laws qualify as illegal any promise, offer, payment, or acceptance, directly or indirectly, of money or other benefits to obtain or retain business or to secure an unfair advantage in business activities by the Company's representatives, Business Partners, or anyone acting on its behalf.

In this regard, the Company does not tolerate any form of corruption and is committed to complying with anti-corruption regulations in force in all countries where it operates, either directly or through subsidiaries.

The Anti-Corruption Guidelines adopted by the Company aim to provide a systematic framework of principles, rules of conduct, and controls to:

  • Prevent company directors, employees, consultants, collaborators, and partners from being involved in any corrupt activities in any capacity.
  • Detect, report, and manage any cases of corruption that may occur.
  • Ensure the compliance of company activities with anti-corruption laws.

The conduct principles indicated in the Anti-Corruption Guidelines aim to identify and articulate corruption prevention strategies on which specific protocols, operational instructions, and procedures are based to prevent corruption risks.

The Anti-Corruption Guidelines, available for download from this page, should be considered in conjunction with the Code of Ethics and the Organizational, Management, and Control Model pursuant to Legislative Decree 231/01 applied by the Company.

Anti-Corruption Policy

U. Del Corona & Scardigli S.r.l. adopts a firm and absolute prohibition approach towards any form of corruption. This anti-corruption policy applies to all personnel, who must observe the highest standards of integrity and moral conduct.

The Company is committed to complying with all anti-corruption laws, regulations, and rules in Italy and in all countries where it operates.

Relationships with Public Officials and Private Entities

The Company is committed to conducting its commercial activities and business in such a way that it is not involved in any corrupt practices and does not facilitate or risk involvement in illegal situations: this applies to both relationships with Public Officials and Private Entities.

In particular, any type of corruption in any form or manner in any jurisdiction is prohibited, even if such activities are practically accepted, tolerated, and not prosecuted judicially.

Additionally, it is strictly forbidden to:

  • Offer, promise, give, pay, or authorize, or accept/request gifts or other benefits that:
  • May induce a Public Official, a Public Service Officer, or a private individual to improperly perform their duties or any other activity or reward them for doing so.
  • May influence an act (or omission) or any decision by a Public Official, Public Service Officer, or private individual in violation of an official duty or obligation of loyalty.
  • Are aimed at obtaining any type of benefit not only for the Company’s interest and/or advantage but also for personal interest and/or advantage or that of family members or acquaintances.
  • All transactions must be accurately recorded in accordance with accounting principles in a complete and transparent manner to trace all receipts, payments, and generally all transactions.
  • These limitations apply not only to cash payments but also to any indirect benefit, including, but not limited to: gifts; stays/hospitality; contributions to associations or sponsorships; business activities; job positions; professional or consulting assignments; investment opportunities; confidential market or product information; discounts or payment extensions; hospitality expenses for third parties such as entertainment, meals, transportation.

All employees of U. Del Corona & Scardigli S.r.l. and all third parties collaborating with them are required to read, understand, and implement this Anti-Corruption Policy. Each director and manager is responsible for ensuring compliance with the Anti-Corruption Compliance system by their collaborators.

Reporting

If clarifications are needed regarding the content of this Policy or the application of its provisions, or for any other necessary advice or to report illegal actions by others, all recipients are invited to seek advice from the Anti-Corruption Support Unit by writing an email to:

Anti-Corruption Support Unit
Compliance Function
anti-corruption@delcoronascardigli.com

Disciplinary Measures

The policies and procedures contained in this Policy are an integral part of the corporate Compliance program of U. Del Corona & Scardigli S.r.l. Any employee or collaborator who does not act in accordance with this Policy or fails to report known or suspected illegal actions by others will be subject to disciplinary action proportional to the severity of the violation (including sanctions provided by relevant labor contracts or removal from office, in addition to possible legal actions in the competent judicial offices). Heads of each Department and corporate function must actively encourage their collaborators to observe the policies and procedures contained in this Policy and will be subject to disciplinary actions if they are aware that conduct prohibited by these policies and procedures is perpetrated by employees under their supervision and have not taken necessary and appropriate corrective measures.